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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #20-0048

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: SorbTech, Inc.

Individual Name: Joanna Kilburn

Location State: IN Country: US

View the Interpretation Document

Response text:

August 3, 2020

Joanna Kilburn
SorbTech, Inc.
1305 Veterans Parkway, Suite 600
Clarksville, IN  47129

Reference No. 20-0048

Dear Ms. Kilburn:

This letter is in response to your June 25, 2020, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to marking requirements. You state you have a machine classified and described as "UN3363, Dangerous Goods in Machinery or Dangerous Goods in Apparatus, 9," which contains a lithium ion battery that can be classified and described as "UN3481, Lithium ion batteries contained in equipment, including lithium ion polymer batteries, 9." When the machine or apparatus is shipped domestically by air and ground transportation, you state it is packaged in a non-specification cardboard box (e.g., strong outer packaging), which is then secured to a pallet with shrink-wrap. You ask whether it is acceptable to apply the required markings to the outside of the shrink-wrap instead of the cardboard box (i.e., instead of the package).

The answer is no. A person who offers a hazardous material for transportation must mark and label the package accordingly, for instance a person must mark a non-bulk package with the proper shipping name and identification number. Shrink-wrapping a package to a pallet is an example of an overpack, where the overpack provides protection or convenience in handling of a package or consolidates two or more packages (see § 171.8). If the markings and labels on the package are not visible through the shrink-wrap, the shrink-wrapped pallet must display the required marking(s) and label(s) as prescribed in § 173.25(a)(2).

I hope this information is helpful. Please contact us if we can be of further assistance.


Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division

171.8, 173.25(a)(2)

Regulation Sections

Section Subject
171.8 Definitions and abbreviations
173.25 Authorized packagings and overpacks